BIO Submits Comments to the EPA’s 2014 RVO Proposed Rule

BIO Submits Comments to the EPA’s 2014 RVO Proposed Rule

By Caitlin Kennedy, 01/30/2014

The public comment period for the Environmental Protection Agency’s (EPA) 2014 proposal on the Renewable Volume Obligations (RVO) closed Tuesday January 28, 2014, with the agency receiving 16,575 comments. On behalf of its members, BIO submitted over fifty pages of comments, stressing that the proposed changes to the RFS would be detrimental to the cellulosic and advanced biofuels industry.

In a recent press release, Brent Erickson, executive vice president of BIO’s Industrial & Environmental Section, stated that “a court would not likely uphold the 2014 RFS rule as proposed, given that EPA’s proposed interpretation of its authority under the general and cellulosic waiver authorities exceeds the bounds of appropriate deference under the law.”

More notably, as part of its comments, BIO conducted a study of the greenhouse gas emission impacts of the proposed rule from 2013 to 2022. Using the GREET1.2013 life cycle model, BIO was able to calculate the 2013 emissions from the amount of petroleum and biofuel actually used during the year and then compare this result to the estimated emissions from the projected use of petroleum and biofuels under the EPA’s proposal, the statutory volumes called for in the RFS, and a scenario where the cellulosic biofuel volumes are reduced.

BIO also projected the EPA’s newly outlined methodology for setting the RFS volumes for 2014 through 2022, and then compared them to the statutory RFS volumes. Here is what they found:

Emissions from the transportation sector will increase in 2014 – compared to 2013 – if EPA finalizes the RFS rule along the lines they’ve proposed.

In fact, greenhouse gas emissions will increase in 2015 and 2016 as well, if EPA extends this proposal into those years. Emissions from transportation would remain above the 2013 level for the next six years, through 2019.

Emissions increase because transportation fuel consumption – both gasoline and diesel – is projected to rise over the next few years. Diesel use continues to rise through 2022.

That means, if EPA sets lower standards for use of renewable fuels, the United States will automatically use more petroleum fuels – with higher emissions as a result.

The policy is equivalent to putting millions of more cars on the road over the next decade – 5.9 million in 2014 alone.

The cumulative added emissions from EPA’s methodology over the entire period through 2022 approach 1 billion metric tons of CO2 equivalent.

Only by maintaining the RFS, with increasing market space for advanced biofuels, can the United States continue to reduce emissions from transportation.